I have been resisting comment, as I know I'll be shot down in flames, but hey, what the heck!! I personally lost a lot of faith in 2006 when (bowing to pressure from the 'industry') the acceptable excess risk was raised from 1x10-6 to 1x10-5 by the way forward. I think fundamentally the difference between part2A & planning is the duty of care that regulators feel they owe their residents (generally not professionals in the contaminated land or toxicological field) under planning - in particular when approached by potential purchasers of new builds for clarification. I won't easily be persuaded to accept C4SLs under planning, although I WILL accept a fully justified SSAC derived for a specific site/end use. Any consultant with sufficient knowledge & understanding to propose the use if C4SLs should have no problem in providing a CoC DQRA that (comprehensively) supports the use of those values under the planning regime.

S

Sarah Haines
Lake Environmental Limited
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> On 18 Jul 2014, at 13:34, Richard Boyle <[log in to unmask]> wrote:
> 
> Chris
> 
> That has taken things incredibly too far.  How dare you imply that I, or anyone else, effectively doesn't mind killing people or causing cancer.   How dare you say that the "RB policy" is what you suggest.  I am extremely offended.
> 
> But as you rightly say " So country wide 5 mg/kg versus 1 mg/kg BaP would add max 0.002% cancers to the mix..." - not exactly SPOSH is it?!  Not all of those cancers are deaths, are they?  So, overall, that is "low".
> 
> Now, go figure on the other impacts of unnecessary road movements, where an assessment of official statistics, carried out by the Metropolitan Transport Research Unit (MTRU) for Campaign for Better Transport, showed that the ratio of fatal road accidents involving Heavy Good Vehicles (HGVs) compared with those involving other vehicle types has been climbing year on year:
> 
> - On motorways: More than half (52%) of fatal accidents on motorways involve HGVs, despite HGVs only making up 10% of the traffic on motorways
> - On A-roads: HGVs are involved in 1 in 5 fatal crashes on A roads, a ratio that has worsened over the last 5 years
> - On minor roads: An HGV is five times as likely to be involved in a fatal accident on a minor road than other traffic
> 
> So, some hypothetical extra cancer risk or a DEATH on the roads from all those trucks taking off marginally impacted soils to bring on topsoil.  And not to mention the extra particulate matter from all those diesel fumes, more BaP being deposited to make matters worse, air quality deteriorating, asthma rates rising, finite fuel reserves being used up, congestion being cause, roads deteriorating, rubber particles from tyres polluting watercourses, silt run-off, CO2 being produced, etc, etc,
> 
> I know I'd rather have cancer and life than being hit by a truck!
> 
> Regards
> 
> Richard
> ______________
> Dr Richard Boyle, BSc (Hons) MSc PhD MIEnvSc
> Senior Technical Manager
> 
> Public Land Acquisitions/Transfers Team  |  Land Team  |  Homes and Communities Agency
> 
> Email: [log in to unmask]
> Telephone: 01925 64 4821
> Mobile: 07767 424 447
> 
> 
> -----Original Message-----
> From: Chris Dainton [mailto:[log in to unmask]]
> Sent: 18 July 2014 12:23
> Subject: Impact of remediation to 5 mg/kg BaP instead of 1 mg/kg
> 
> With regards to the last slide in RB NWBR presentation.
> 
> 
> There are other ways to view the impact of remediation to 5 mg/kg instead of to 1 mg/kg.
> 
> Using the numbers presented by RB, exposure to:
> 
> 5 mg/kg BaP = 10 additional cancers per million population (over lifetime)
> 1 mg/kg BaP = 2 additional cancers per million population (over lifetime)
> 
> So having 5 mg/kg instead of 1 mg/kg = 8 additional cancers per million population
> 
> Applied across UK Population of 63M, this policy approach could theoretical add c. 500 cancers into the UK... (dodgy calc I know, but gives a nice population wide upper bound)
> 
> (but also need to be remember that increasing BaP soil loading, will also increases other PAH soil loading, so cancers due to other PAHs could also be increased by a factor of 5)
> 
> 
> Other factors to consider: c. 330,000 new cancer cases per year in UK (cancer research UK).
> 
> So say over 50 years = 16.5 Million cases
> 
> Or using the 1/3 get cancer rule of thumb = 31M lifetime cancer cases in snap shot of population
> 
> So country wide 5 mg/kg versus 1 mg/kg BaP would add max 0.002% cancers to the mix...
> 
> 
> Devils Advocate: So if we continue the RB thought process to its logical conclusion, there really is a strong case for not worrying about any cancer inducing contaminants in soil in the greater scheme of things as it is a drop in the ocean..: so how about a RB land contamination regime based on: "if it looks like a soil, it will be fine, any potential impact to health are not really worth worrying about in the greater scene of things" ...
> 
> 
> .... playing with numbers is a dangerous thing.  'Careful with That Calculator, Eugene". (some of you might get that).
> 
> 
> Chris Dainton
> 
> Peak Environmental Solutions
> http://peakenvironmentalsolutions.com/
> 
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